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SEC Company Response from NIKU CORP (CIK 0001076641) — Dec 14, 2004

NIKU CORP (CIK 0001076641)
Date: Dec. 14, 2004 · CIK: 0001076641 · Accession: 0001193125-04-212853

AI Filing Summary & Sentiment

File numbers found in text: 333-120653

Date
December 15, 2004
Author
SG COWEN & CO., LLC
Form
CORRESP
Company
NIKU CORP (CIK 0001076641)

Letter

Re: Niku Corporation Registration Statement on Form S-3 (File No. 333-120653)—Acceleration Request

Acceleration Request

December 14 , 2004

VIA EDGAR AND FACSIMILE: (202) 942-9544

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Attention: Jeffrey B. Werbitt

Ladies and Gentlemen:

Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, Niku Corporation (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form S-3 (File No. 333-120653) (the “Registration Statement”), relating to the registration of 3,000,000 shares of the Company’s common stock, $0.0001 par value per share, so that the Registration Statement may be declared effective at 4:00 p.m., E.S.T., on December 15, 2004, or as early as practicable thereafter.

We request that we be notified of such effectiveness by a telephone call to Robert Zivnuska at (415) 984-6475, and that such effectiveness also be confirmed in writing. Thank you.

Very truly yours,

NIKU CORPORATION

By:

/s/ Joshua Pickus

Name: Joshua Pickus

Title: President and Chief Executive Officer

cc: Gregory C. Smith, Esq.

Celeste E. Greene, Esq.

[Deutsche Bank Securities Inc. letterhead]

December 14, 2004

Securities and Exchange Commission

Division of Corporation Finance

Judiciary Plaza

450 Fifth Street, N.W.

Washington, D.C. 20549

Re:

Niku Corporation

Registration Statement on Form S-3

File No. 333-120653

Ladies and Gentleman:

The following information with respect to the distribution of the prospectus dated December 6, 2004 is furnished pursuant to Rule 460 of the Rules and Regulations of the Commission under the Securities Act of 1933, as amended, in connection with the request for acceleration of the effective date of the aforementioned Registration Statement.

The number of prospectuses dated December 6, 2004 as distributed between December 6, 2004 and December 14, 2004 is as follows:

No. of Copies dated December 6, 2004

To Prospective Underwriters

5,000

To Institutions

1,450

To Statistical and Publicity Services

Total

6,453

Sincerely,

DEUTSCHE BANK SECURITIES INC.

NEEDHAM & COMPANY, INC.

SG COWEN & CO., LLC

AMERICA’S GROWTH CAPITAL, LLC

As Representatives

By: Deutsche Bank Securities Inc.

/s/ Carleigh Jaques

/s/ Ghazaleh Lyari

Carleigh Jaques

Managing Director

Ghazaleh Lyari

Director

[Deutsche Bank Securities Inc. letterhead]

December 14, 2004

Securities and Exchange Commission

Division of Corporation Finance

Judiciary Plaza

450 Fifth Street, N.W.

Washington, D.C. 20549

Re:

Niku Corporation

Registration Statement on Form S-3

File No. 333-120653

Ladies and Gentleman:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned hereby join in the request of the Company that the effective date of the Registration Statement be accelerated so that the Registration Statement may become effective by 4:00 p.m., E.S.T., on the afternoon of December 15, 2004 or as soon thereafter as practicable.

Sincerely,
DEUTSCHE BANK SECURITIES INC.

Show Raw Text
CORRESP
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filename1.htm

Acceleration Request

 December 14 , 2004

 VIA EDGAR AND FACSIMILE: (202) 942-9544

 Securities and Exchange Commission

 450 Fifth Street, N.W.

 Washington, D.C. 20549

 Attention: Jeffrey B. Werbitt

Re:
Niku Corporation Registration Statement on Form S-3 (File No. 333-120653)—Acceleration Request

 Ladies and Gentlemen:

 Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, Niku Corporation (the “Company”) hereby
requests acceleration of the effective date of its Registration Statement on Form S-3 (File No. 333-120653) (the “Registration Statement”), relating to the registration of 3,000,000 shares of the Company’s common stock, $0.0001 par
value per share, so that the Registration Statement may be declared effective at 4:00 p.m., E.S.T., on December 15, 2004, or as early as practicable thereafter.

We request that we be notified of such effectiveness by a telephone call to Robert Zivnuska at (415) 984-6475, and that such effectiveness also be
confirmed in writing. Thank you.

 Very truly yours,

 NIKU CORPORATION

By:

/s/    Joshua Pickus

 Name: Joshua Pickus

 Title: President and Chief
Executive Officer

cc:
Gregory C. Smith, Esq.

 Celeste E. Greene, Esq.

 [Deutsche Bank Securities Inc. letterhead]

 December 14, 2004

 Securities and Exchange Commission

 Division of Corporation Finance

 Judiciary Plaza

 450 Fifth Street, N.W.

 Washington, D.C. 20549

Re:

Niku Corporation

Registration Statement on Form S-3

File No. 333-120653

 Ladies and Gentleman:

 The following information with respect to the
distribution of the prospectus dated December 6, 2004 is furnished pursuant to Rule 460 of the Rules and Regulations of the Commission under the Securities Act of 1933, as amended, in connection with the request for acceleration of the effective
date of the aforementioned Registration Statement.

 The number of prospectuses dated
December 6, 2004 as distributed between December 6, 2004 and December 14, 2004 is as follows:

No. of Copies dated
December 6, 2004

 To Prospective Underwriters

5,000

 To Institutions

1,450

 To Statistical and Publicity Services

3

 Total

6,453

 Sincerely,

 DEUTSCHE BANK SECURITIES INC.

 NEEDHAM & COMPANY, INC.

 SG COWEN & CO., LLC

 AMERICA’S GROWTH CAPITAL, LLC

     As Representatives

 By: Deutsche Bank Securities Inc.

/s/    Carleigh Jaques

/s/    Ghazaleh Lyari

 Carleigh Jaques

 Managing Director

 Ghazaleh Lyari

 Director

 [Deutsche Bank Securities Inc. letterhead]

 December 14, 2004

 Securities and Exchange Commission

 Division of Corporation Finance

 Judiciary Plaza

 450 Fifth Street, N.W.

 Washington, D.C. 20549

Re:

Niku Corporation

Registration Statement on Form S-3

File No. 333-120653

 Ladies and Gentleman:

 Pursuant to Rule 461 under the Securities Act of 1933, as
amended, the undersigned hereby join in the request of the Company that the effective date of the Registration Statement be accelerated so that the Registration Statement may become effective by 4:00 p.m., E.S.T., on the afternoon of December 15,
2004 or as soon thereafter as practicable.

 Sincerely,

 DEUTSCHE BANK SECURITIES INC.

 NEEDHAM & COMPANY, INC.

 SG COWEN & CO., LLC

 AMERICA’S GROWTH CAPITAL, LLC

 As Representatives

 By: Deutsche Bank Securities Inc.

/s/    Carleigh Jaques

/s/    Ghazaleh Lyari

 Carleigh Jaques

 Managing Director

 Ghazaleh Lyari

 Director